The
defendant is charged [in count __]
with interfering with an emergency
call. The statute defining this
offense reads in pertinent part as
follows:

a
person is guilty of interfering
with an emergency call when such
person, with the intent of
preventing another person from
making or completing (a 911
telephone call / telephone call or
radio communication to any law
enforcement agency) to (request
police protection / report the
commission of a crime),
(physically / verbally) prevents
or hinders such other person from
making or completing such
(telephone call / radio
communication).

For you
to find the defendant guilty of
this charge, the state must prove
the following elements1 beyond
a reasonable doubt:

Element
1 - Prevented callThe
first element is that the
defendant (physically / verbally)
prevented or hindered another
person from making or completing a
(911 telephone call / telephone
call or radio communication to any
law enforcement agency).

Element
2 - Purpose of callThe
second element is that the purpose
of such call was to (request
police protection / report the
commission of a crime).

Element
3 - IntentThe
third element is that the
defendant acted with the specific
intent to prevent the other person
from making or completing such
call. A person acts "intentionally"
with respect to a result when
(his/her) conscious objective is
to cause such result. <See
Intent: Specific, Instruction
2.3-1.>

Conclusion

In
summary, the state must prove
beyond a reasonable doubt that 1)
the defendant (physically /
verbally) prevented or hindered
another person from making or
completing a (911 telephone call
/ telephone call or radio
communication to any law
enforcement agency), 2) the call
was to (request police protection
/ report the commission of a
crime), and 3) (he/she) did so
with the specific intent to
prevent the other person from
making or completing such call.

If you
unanimously find that the state
has proved beyond a reasonable
doubt each of the elements of
interfering with an emergency
call, then you shall find the
defendant guilty. On the other
hand, if you unanimously find that
the state has failed to prove
beyond a reasonable doubt any of
the elements, you shall then find
the defendant not guilty.
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